Redeemable shares with no right to dividends were not effectively shares with a right to a fixed dividend at 0%, and so were ‘ordinary share capital’ for entrepreneurs’ relief purposes, and were required to be taken into account in determining whether the company was the taxpayers’ ‘personal company’ for relief purposes.
Summary
Redeemable non-voting shares with no right to dividends were not effectively shares with a right to a fixed dividend at 0%, and so were ‘ordinary share capital’ for entrepreneurs’ relief purposes, and were required to be taken into account in determining whether the company was the taxpayers’ ‘personal company’ for relief purposes.
Background
The taxpayers (Mr and Mrs Q) established a company in August 2004 and each held 33 ordinary £1 shares out of the company;
